BACKGROUND
[0001] Many service providers use online, or web, registration methods to allow users to
create profiles and accounts linked to their online services, for example websites,
apps, games. These may be implemented for a large variety of reasons such as enabling
customers to shop at an online storefront, accessing of protected pages or information
on a website, or to provide the user with a persistent account that saves a history
of their use of the online service. The collection and processing of user data enables
an online service provider to track and record information related to the activities
of the user.
[0002] Registration methods typically require the prospective user to submit a unique identifier,
such as an email address, and a password that are subsequently stored by the website
operator or a third party acting on behalf of the website operator.
[0003] However, in an increasing number of jurisdictions it is unlawful to collect or use
the personal data of a child without the consent of the child's parent or legal guardian
to do so (referred to as 'legal guardian' herein). Recent legislation such as the
European Union's General Data Protection Regulation (GDPR), and the United States'
Children's Online Privacy Protection Act (15 U.S.C. Ch. 91, herein referred to as
COPPA) have recognised that children's personal data should be granted special protection
because they may be less aware of any risks and consequences of sharing their data.
Similar legislation is being enacted worldwide. COPPA defines a child as an individual
under thirteen years old, while the GDPR sets the age of digital consent as sixteen
years old (though individual member states can choose to lower this to a minimum of
thirteen years old). Some examples of personal data which this legislation may apply
to include a name of the child, screen or user name that functions as online contact
information, a persistent identifier that can be used to recognise a user over time
and across different websites or online services, or a file which contains a child's
image. Collectively this type of personal data may be referred to as personally identifiable
information (Pll). The legislation applies even if the personal data merely forms
part of user-generated content, for example if a child creates an image using an online
tool and the image includes their signature - that is, the data can identify the child.
[0004] These special protections introduce new requirements for the operators of websites
and online services who know they are collecting personal data from children. One
of these requirements is that consent for the processing of the personal data of the
child must be given or authorised by the holder of parental responsibility over the
child.
[0005] In addition, collecting, storing and processing personal data inherently brings about
fraud risks. The greater the number of people who have access to the data, and the
easier it is to access, then the greater the risk of fraud occurring.
[0006] Many current registration methods for online services include an age-gate to determine
whether parental consent is required for the prospective user to use the online service.
However, these methods are not capable of determining whether the necessary consent
has been granted by the appropriate responsible person (e.g. the child's legal guardian)
and so cannot allow the user to complete registration and use the online service,
if consent is required.
[0007] If the online service provider decides to request consent from the legal guardian,
they must seek authorisation for the storage and processing of child personal data
while maintaining compliance with the relevant data protection laws (i.e. without
storing the child personal data themselves, even temporarily).
[0008] The child-legal guardian relationship is an example of a user-supervisor relationship
where this dichotomy exists, i.e. how to seek authorisation to store data without
first storing the data. There currently exists no technical solution to address this
problem.
[0009] Accordingly, there is a need for a method or system capable of seeking and verifying
authorisation for the processing of personal data without storing that same personal
data.
SUMMARY
[0010] According to a first aspect of the present disclosure, there is provided a method
performed by a verification platform for authorising a user incapable of providing
digital consent, the method comprising: receiving sensitive user information and a
unique supervisor identifier; encrypting the sensitive user information using an encryption
scheme with an associated encryption key to generate encrypted user information; sending
an authorisation request message to a supervisor device associated with the unique
supervisor identifier, wherein the authorisation request message comprises the encryption
key and a request for authorisation in response; discarding the sensitive user information
and the encryption key, such that the verification platform cannot access the sensitive
user information; and, if the verification platform receives an authorisation response
message from the supervisor device comprising a received encryption key, decrypting
the encrypted user information using the received encryption key, such that the verification
platform can successfully access the sensitive user information.
[0011] As the verification method requires the discarding of the sensitive user information
and the encryption key, the verification platform is not able to access the sensitive
user information, either by accessing it directly or indirectly by decrypting the
encrypted user information. While the platform stores the encrypted data, it has no
means to decrypt it. Thus the personally identifiable information of a user incapable
of giving consent is not accessible until a message granting authorisation is received.
Advantageously, such an approach maintains compliance with the relevant data protection
regulations while allowing, and ensuring security of, data storage.
[0012] As the authorisation request message, comprising the encryption key, is sent to the
supervisor, the platform presents the supervisor with the ability to grant or refuse
authorisation and manage the encryption key accordingly. It should be noted that,
at all times, the ability to access or read sensitive data is given only to those
persons with the ability to grant consent or those who have positively received it,
thus providing essential control to the supervisor. It is only once the consent-giver
has delegated authority to the verification platform that the sensitive data be subsequently
accessed.
[0013] Once the authorisation response message has been received, the verification platform
may use the encryption key to decrypt the encrypted user identifier and access the
sensitive user information. When the sensitive user information can be accessed, it
can be used by the verification platform (or transmitted to an approved destination
for use) according to the needs of the online service.
[0014] To summarise, the verification method enables personally identifiable information
(PII) to be converted into non-PII, while authorisation for subsequent processing
of the PII is sought, and only converted back into PII once authorisation has been
granted.
[0015] Receiving the authorisation message comprising the received encryption key provides
authorisation from the supervisor (either explicitly or implicitly) for processing
of the unique user identifier. The exact nature and limits of the authorisation provided
may be defined in the authorisation response message, for example, the authorisation
request message may comprise a set of permissions parameters and/or a written statement
of consent. The permissions parameters may be approved individually or as a whole.
Examples of permission parameters for which authorisation is sought may include the
processing of the sensitive user information in a registration process, permission
for the subsequent transmission of the sensitive user information, permission for
the modification of the sensitive user information, permission for direct correspondence
with the user, permission for ancillary services such as charging, etc.
[0016] In an example, the user incapable of providing digital consent may be a child, in
a country where COPPA, GDPR or similar legislation applies, while a supervisor (associated
with the unique supervisor identifier and the supervisor device) may be the holder
of parental responsibility over the child. The verification platform may receive sensitive
user information and a unique supervisor from a registration platform, directly from
a prospective user or from an alternative source. The sensitive user information may
be for example personally identifiable information of the user who is incapable of
providing digital consent, which requires authorisation from the supervisor in order
for it to be processed. This may be, for example, an email address associated with
the user, the name of the user, or a pseudonym of the user.
[0017] The unique supervisor identifier may be, for example, an email address associated
with the supervisor of the user, a telephone number (e.g. MSISDN) associated with
the supervisor of the user, or a website or online service credential associated with
the supervisor of the user.
[0018] Storing the encrypted user information with no means of decrypting it (i.e. without
the encryption key) denies the verification platform any capability of accessing any
information protected by the data protection regulations. This means that the service
provider and/or verification platform operator is complying with the regulations while
being able to process the sensitive user information later (if authorisation is granted
by the supervisor). Furthermore, storing sensitive user information in an encrypted
format increases the security of the data and lowers the risk of fraud, especially
so when the encryption key is discarded.
[0019] As the verification platform discards the encryption key and the sensitive user information,
sending the authorisation request message, which comprises the encryption key or suitable
means of retrieving the encryption key, to a supervisor device provides the operator
of the supervisor device (the supervisor) with the sole means of decrypting the encrypted
user information, and therefore also deciding whether later processing of the sensitive
user information is allowed. The authorisation request message may be, for example,
an email, SMS, API request, or any other means capable of retrieving the encryption
key. The authorisation request message may comprise a token representing the encryption
information. Such tokenisation substitutes the sensitive data element with a non-sensitive
equivalent.
[0020] The verification method employs an encryption scheme with an associated encryption
key to protect the sensitive user information, as these are better suited to securing
and retrieving information rather than alternative cryptographic methods. For example,
a one-way cryptographic hash function may hash the sensitive user information so it
is practically unfeasible to invert. However, this would not allow the verification
platform to retrieve the sensitive user information, after authorisation had been
granted, without already knowing the hashing function. In which case, the hash function
method would have been breaching confidentiality requirements before that point.
[0021] This method may be incorporated into an existing registration process of a service
provider so that the service provider can ensure they are complying with the regulations
without adjusting any of the front-end aspects of their existing registration process.
[0022] Preferably, after discarding the sensitive user information and the encryption key,
the method may further comprise: if the verification platform receives a refusal response
message from the supervisor device, discarding the encrypted user information. The
refusal response message from the supervisor device informs the verification platform
that the supervisor does not grant authorisation for processing of the sensitive user
information. Although continuing to store the encrypted user information, without
means of decrypting it, complies with the confidentiality requirements and the relevant
regulations, the encrypted user identifier may be discarded for data minimisation
purposes. Discarding unnecessary data reduces data storage as well as the risk of
fraud occurring. The supervisor and/or the user may also prefer that the encrypted
user information is not stored and cannot be accessed.
[0023] Additionally or alternatively, after discarding the sensitive user information and
the encryption key, the method may further comprise: if a predetermined period of
time expires without the verification device receiving a response message from the
supervisor device, discarding the encrypted user information. The response message
may be an authentication response message or a refusal response message. If a predetermined
period of time expires without the verification platform receiving an authorisation
response message or a refusal response message, it is assumed that an authorisation
response message will not be received and so the encrypted user information may be
discarded for data minimisation. The predetermined period of time, or timeout interval,
may be, for example, one day, two days, one week, or one month.
[0024] Furthermore, as the encryption key and sensitive user information are discarded there
is no way for the verification platform to identify duplicate requests related to
permissions for the same item of sensitive user information. Therefore, if repeated
requests are sent, data storage could escalate beyond that which is required. Discarding
the encrypted user information prevents this situation arising.
[0025] The received encryption key may be thought of as any key suitable for decrypting
the sensitive user information depending on the applied encryption scheme, this may
also be called a decryption key and the terms used interchangeably. In certain embodiments,
the method may further comprise, before encrypting the unique user identifier: pseudo-randomly
generating an encryption key. Randomly generating the encryption key provides that
that the encryption key cannot feasibly be regenerated and thereby ensures the encrypted
user information is not retrievable or replicable.
[0026] Preferably, the encryption key is unique. Using a unique encryption key increases
security. Though pseudo-randomly generating the encryption key does not guarantee
that the encryption key will be unique, as no record of the encryption key is kept
by the verification platform, the verification platform will be unable to tell whether
the key is a duplicate and so it can be assumed the encryption key is unique.
[0027] Preferably, after the encrypting, the method may further comprise: creating an authorisation
request record, in a verification database, comprising the unique supervisor identifier
and the encrypted user information; storing the authorisation request record in the
verification database; and, if the verification platform receives an authorisation
response message, retrieving the authorisation request record from the verification
database. Similarly, the method may further comprise, if the verification platform
receives a refusal response message, or a predetermined period of time expires without
receiving an authentication response message or a refusal response message, retrieving
the authorisation request record from the verification database.
[0028] Creating and storing an authorisation request record, comprising the unique supervisor
identifier and the encrypted user information, in a database provides an association
between the unique supervisor identifier and the encrypted user information that the
verification platform can access if necessary. For example, after receiving an authorisation
response message from the supervisor device, the verification platform can locate
and retrieve the authorisation request record from the database in order to decrypt
the encrypted user information. Alternatively, after receiving a refusal response
message, or after waiting a predetermined period of time, the verification platform
can delete or amend the authorisation request record from the database in order to
discard the encrypted user information and/or the unique supervisor identifier for
data minimisation.
[0029] In preferred embodiments, the method may further comprise, before sending the authorisation
request message: encoding the encryption key into the authorisation request message.
In this way the message itself comprises the encryption key. In alternative embodiments,
the message may comprise a pointer to a secure location from which the encryption
key can be retrieved.
[0030] The authorisation request message may further comprise an authenticated URL suitable
for granting permission to decrypt the sensitive user information and sending the
authorisation response message from the supervisor device to the verification platform.
The authenticated URL provides passwordless authentication, enabling the supervisor
to provide authorisation and return the encryption key with low user friction. The
authenticated URL may otherwise be referred to as a magic link. The authenticated
URL preferably comprises a token representing the encryption key and/or the sensitive
user information. Tokenisation in this way provides a secure means to transfer the
necessary information and a user-friendly way to transmit the key needed for decryption
back to the verification platform.
[0031] According to a second aspect of the present invention, there is provided a verification
platform configured to perform any of the above aspects of the user verification method.
[0032] According to a third aspect of the present invention, there is provided a verification
platform configured to perform a method for authorising a user incapable of providing
digital consent, the verification platform being further configured to: receive sensitive
user information and a unique supervisor identifier; encrypt the sensitive user information
using an encryption scheme with an associated encryption key to generate encrypted
user information; send an authorisation request message to a supervisor device associated
with the unique supervisor identifier, wherein the authorisation request message comprises
the encryption key and a request for authorisation in response; discard the sensitive
user information and the encryption key, such that the verification platform cannot
access the sensitive user information; and, if the verification platform receives
an authorisation response message from the supervisor device comprising a received
encryption key, decrypt the encrypted user information using the received encryption
key, such that the verification platform can successfully access the sensitive user
information.
[0033] The verification platform may be further configured to, after discarding the sensitive
user information and the encryption key, if the verification platform receives a refusal
response message from the supervisor device, discard the encrypted user information.
[0034] The verification platform may be further configured to, after discarding the sensitive
user information and the encryption key, if a predetermined period of time expires
without the verification device receiving a response message from the supervisor device,
discard the encrypted user information.
[0035] The verification platform may be further configured to, before encrypting the sensitive
user information the, pseudo-randomly generate an encryption key.
[0036] The verification platform may be further configured to, after the encrypting, create
an authorisation request record, in a verification database, comprising the unique
supervisor identifier and the encrypted user information; store the authorisation
request record in the verification database; and, if the verification platform receives
an authorisation response message, retrieve the authorisation request record from
the verification database.
[0037] The verification platform may be further configured to, wherein before sending the
authorisation request message, encode the encryption key into the authorisation request
message. The authorisation request message may further comprise an authenticated URL
for granting permission to decrypt the sensitive user information and sending the
authorisation response message from the supervisor device to the verification platform.
The authenticated URL may comprise a token representing the encryption key and/or
the sensitive user information.
[0038] According to a fourth aspect of the present disclosure, there is provided a user
registration method performed by a registration platform for registering a user incapable
of providing digital consent, the method comprising: receiving sensitive user information
and user consent information; identifying, using the user consent information, whether
a user is capable of providing digital consent; and, if the user is not capable of
providing digital consent, the method further comprises: receiving a unique supervisor
identifier; sending the sensitive user information and the unique supervisor identifier
to a verification platform; and subsequently discarding the sensitive user information.
The verification platform may be the verification platform of any of the above aspects
of the invention. For example, the verification platform may be configured to carry
out the first aspect of the invention as set out above.
[0039] The registration platform may receive the sensitive user information and user consent
information directly from a user, or from another party or service provider to which
the user has provided the sensitive user information and user consent information,
for example an age-gate provider. Using the user consent information, the registration
platform determines whether the user is capable of providing digital consent. For
example, the user may be a child, in a country where COPPA, GDPR, or similar legislation
applies and so is not capable of providing digital consent. If this is the case, the
registration platform discards the sensitive user information, after sending it to
a verification platform along with the unique supervisor identifier, and so does not
have access to any information protected by the data protection regulations. Therefore,
the service provider and/or registration platform operator is complying with the regulations
while being able to process the sensitive user information later (if authorisation
is granted by the supervisor).
[0040] Preferably, the method may further comprise, after discarding the sensitive user
information: receiving the sensitive user information from the verification platform
following successful authorisation at the verification platform, such that the user
registration method can store and access the sensitive user information. The registration
platform may receive sensitive user information from the verification platform if
the supervisor of the user has provided authorisation, through a part of a user verification
method, for the sensitive user information to be processed. The registration platform
can therefore use the received sensitive user information in processes for which authorisation
has been granted, such as completing a user registration method for an online service,
without breaching confidentiality.
[0041] The method may further comprise: creating a registration request record, in a registration
database, comprising the unique supervisor identifier; and storing the registration
request record in the registration database. By creating and storing a registration
request record, comprising the unique supervisor identifier, in a database, it is
possible to store a registration state associated with the unique supervisor identifier.
This may allow, for example, the registration platform to prevent the supervisor receiving
duplicate authentication request messages while an earlier authentication request
message is still pending and has not been addressed by the supervisor. Thus the method
may further comprise, after receiving the unique supervisor identifier, checking the
identifier against the database and, if the unique supervisor identifier exists in
the database, not sending the sensitive user information and the unique supervisor
identifier to a verification platform.
[0042] According to a fifth aspect of the present invention, there is provided a registration
platform configured to perform any of the above aspects of the user registration method.
[0043] According to a sixth aspect of the present invention, there is provided a registration
platform configured to perform a user registration method for a user incapable of
providing digital consent, the registration platform being further configured to:
receive sensitive user information and user consent information; identify using the
user consent information, whether a user is capable of providing digital consent;
and, if the user is not capable of providing digital consent, the method further comprises:
receive a unique supervisor identifier; send the sensitive user information and the
unique supervisor identifier to a verification platform; and subsequently discard
the sensitive user information.
[0044] The registration platform may be further configured to, after discarding the sensitive
user information: receive the sensitive user information from the verification platform
following successful authorisation at the verification platform, such that the user
registration method can store and access the sensitive user information.
[0045] The registration platform may be further configured to: create a registration request
record, in a registration database, comprising the unique supervisor identifier; and
store the registration request record in the registration database.
[0046] According to a seventh aspect of the present invention, there is provided a system
for performing a user registration and verification method, the system comprising:
the registration platform described above; and the verification platform described
above.
[0047] The verification platform and registration platform may be separate and discrete
entities. For example, the verification platform and registration platform may be
operated separately; the registration platform by a service provider and the verification
platform may be operated by a verification provider. Alternatively, the verification
platform and registration platform may be comprised or integrated in the same system.
For example, the verification platform and registration platform may be combined into
a system that is operated by a single operator. In a second example, the registration
platform and/or method may be embedded in an application of an online service provider,
while the verification platform and/or method may be operated by a different online
service provider.
[0048] According to a further aspect of the present invention, there is provided a computer
readable medium comprising instructions which, when executed by a processor, cause
the processor to: perform the method of the first aspect described above and/or perform
the user registration method of the fourth aspect described above.
BRIEF DESCRIPTION OF DRAWINGS
[0049] An example of the present invention will now be described in detail with reference
to the accompanying drawings, in which:
Figure 1 shows, schematically, a system comprising a verification platform and a registration
platform.
Figure 2 shows a process flow of a verification method performed by a verification
platform;
Figure 3 shows a process flow of a registration method performed by a registration
platform; and
Figure 4 shows a process flow of a registration and verification method performed
by a system.
DETAILED DESCRIPTION
[0050] Registration and verification methods, apparatus and systems will now be described
in relation to several figures and process flows. This is to set out the required
and optional steps as well as to provide context for the implementation of the methods
using example scenarios.
[0051] The verification method and registration method are described in figures 2 and 3
respectively while figure 4 provides an example implementation where the verification
method and registration method are combined. Figure 1 shows a system for performing
a registration method and verification method, demonstrating the interactions (the
steps described in figures 2, 3 and 4) between the different components of the system.
[0052] In the following examples, digital consent refers to the legal requirement for consent
for the processing of the personal data of those incapable of providing digital consent,
such as a child. Consent is typically to be provided by the holder of parental responsibility
over the child. However, digital consent is not limited to this example and may refer
to any scenario where authorisation is required for collection and/or use of information
or data in any way.
[0053] The data concerned may be personally identifiable information (PII); this is any
data that can be used to identify a specific, living individual and has a very broad
scope. For example, PII may be an email address, phone number, IP address, digital
image, biometric or behavioural data. Different jurisdictions may class PII in different
ways so it is important to be aware which apply and, if uncertain, presume the information
is Pll. Again, the methods described herein may be applicable to any situation in
which authorisation may be provided for the storage of data, noting the particular
applicability to the authorisation to store personally identifiable information, such
authorisation being potentially provided by a third-party.
[0054] In these examples, a user incapable of providing digital consent is a child below
the age of thirteen. However, the method is not limited to being performed in relation
to children below a threshold age and the user may be any person who requires another
party (herein referred to as a supervisor) to provide authorisation for collection
and/or use of their personal data. For example, the verification method may also be
used when an online service provider is seeking permission from a third party to store
user-generated content.
[0055] Figure 1 shows an example of a system comprising a user device 10, supervisor device
12, registration platform 14, verification platform 16, registration database 18 and
a verification database 20.
[0056] The user device 10 is a device through which a user interacts with an online service
or website, for example using a native app and corresponding web service or API or
a web app. In the context of the invention, this interaction includes providing sensitive
user information to the online service.
[0057] The supervisor device 12 is a device associated with a unique supervisor identifier.
In one example, if the unique supervisor identifier is an email address associated
with the supervisor, a supervisor device 12 may be a device on which the supervisor
may access their email messages stored centrally. In another example, if the unique
supervisor identifier is a username, for an application, associated with the supervisor,
then a supervisor device 12 may be a device on which the supervisor may access their
account for the application. In a further example, the unique supervisor identifier
is a phone number or MSISDN associated with a mobile phone of the supervisor. In this
further example, messages are not stored centrally but are delivered directly to the
device associated with the MSISDN using, for example, SMS or an IP-based messaging
service. Messages and/or information may also be uploaded to secure server for subsequent
retrieval by the supervisor device using a unique identity.
[0058] Though figure 1 shows the registration platform 14 and the verification platform
16 as separate entities this is not required by the invention. Other embodiments may
include the registration platform 14 and the verification platform 16 combined and
integrated into a single platform.
[0059] An example scenario employing an embodiment of the user registration method and the
user verification method of the present invention will be described in the context
of a child attempting to create an account for an online game using their email address.
More detailed explanations of the steps, and alternative steps, may be found below
in the description of figures 2, 3 and 4.
[0060] First, the child (using their user device 10) enters their email address and age
(e.g. date of birth) into an account creation service (the registration platform 14)
used for the online game (step S201) provided by an online service provider. The registration
platform 14 determines (step S202), by comparing the age of the child to the age of
digital consent in the relevant country, that they are incapable of providing digital
consent and so parental consent is required in order to process the child's email
address (which is necessary for the game).
[0061] After prompting, the child then provides the registration platform 14 with their
legal guardian's email address or the individual with parental responsibility (step
S203). The registration platform 14 goes on to send both the child's email address
and their legal guardian's email address to a verification platform 16 in order to
verify whether the legal guardian has given consent for the processing of the child's
email address (step S205). Following this step, the registration platform 14 discards
the child's email address (step S206). As the registration platform 14 no longer possesses
PII of the child then the online service provider is not able to identify that child
and thus are not breaching data protection regulations.
[0062] The verification platform 16 receives the email addresses of the child and the legal
guardian sent by the registration platform 14 (step S101). Following this, in step
S103, the verification platform 16 encrypts the child's email address using an encryption
key to generate an encrypted version of the child's email address (referred to as
the encrypted email address). The encryption key was generated before step S103 was
performed (step S102) and a symmetric-key encryption scheme is used to encrypt the
child's email address.
[0063] The encrypted email address will be unreadable and unrecognisable compared to the
child's email address. Decryption is required (using the correct key for decryption)
in order to make sense of the encrypted email address and retrieve the child's email
address.
[0064] The encryption key is encoded into an authorisation request message (step S105) which
is subsequently sent to the legal guardian (through a device of the legal guardian
12) using their email address (step S106). This message requests the legal guardian
to give authorisation for their child's email address to be used by the game (and
the necessary processing by the verification platform 16).
[0065] After the authorisation request message has been sent, the verification platform
16 discards the child's email address and the encryption key that was used to encrypt
it. Now the verification platform 16 does not have access to the child's email address
directly or indirectly through the encrypted email address (as the encryption key
has been discarded) and so it complies with the data protection regulations.
[0066] The legal guardian views the authorisation request message on their device 12 and
approves the request for authorisation, sending back an authorisation response message
to the verification platform 16 (step S108). This response message includes the key
required to decrypt the encrypted email address, which, in this example, is the same
as the key used for encryption.
[0067] Once the verification platform 16 has received the response message granting authorisation,
it can decrypt the encrypted email address using the received encryption key (step
S109) to access the child's email address (with authorisation to do so). Now that
the registration platform 14 (linked to the game the child is attempting to play)
has permission to use the child's email address, the verification platform 16 sends
a verification grant message (which includes the child's email address and a notice
of the permissions given) to the registration platform 14 (step S110).
[0068] As permission for use of the child's email address has been granted, the child is
able to complete the account creation process for the online game using their email
address and the service provider of the online game is complying with the relevant
data protection regulations.
[0069] In an alternative scenario, the child does not enter their own email address during
account creation but instead uses their legal guardian's email address, along with
another piece of PII, such as a username. In the scenario, it is this piece of PII
which the registration platform sends to the verification platform and subsequently
discards.
[0070] In another alternative scenario, a child has created an image (user-generated content),
part of which contains a representation of the child, using a graphics editor. The
child is attempting to upload it to a storage server, owned by the provider of the
graphics editor, so that they can access and edit the image remotely. Similarly to
the previous scenarios, if the image is stored by the service provider of the graphics
editor without parental consent, they may not be complying with data protection regulations
(as the representation of the child could be sensitive user information or contain
PII - that platform does not know).
[0071] Figure 2 shows a process flow outlining a user verification method performed by a
verification platform 16 for a user incapable of providing digital consent. The user
verification method may be used to gain authorisation from a third party for use of
the PII of a user for which the third party holds a position of responsibility. First,
in step S101, the verification platform 16 receives sensitive user information A and
a unique supervisor identifier S.
[0072] The sensitive user information A is information associated with the user. For example,
the sensitive user information A may be personal data of the child such as an email
address, a name, or a pseudonym used by the child.
[0073] Similarly, the unique supervisor identifier S is information associated with a supervisor
of the user and may be almost any form of unique identifier that allows the registration
platform to contact the supervisor. For example, the unique supervisor identifier
S may be an email address associated with the supervisor, an online service username,
or an MSISDN.
[0074] Optionally, before encrypting the sensitive user information A (step S103 below),
the verification platform 16 generates an encryption key K (step S102).
[0075] The generated encryption key K will be used later in the method to encrypt the sensitive
user information A and/or decrypt an encrypted user identifier. The nature of the
encryption key generated will depend on the type of encryption scheme implemented
in the verification method. Similarly, the decryption key will depend on the encryption
scheme and the associated encryption key used, that is, the decryption key may be
the same as the encryption key or may be different.
[0076] It is preferred that the encryption key is unique as this increases the security
of the encryption scheme and therefore the verification. Pseudo-randomly generating
the encryption key is likely to produce a unique key although this is not guaranteed.
However, as the verification platform 16 does not store any record of the encryption
key, it will be unable to tell whether the key is a duplicate and so it can be assumed
that the encryption key is unique.
[0077] Next, in step S103, the sensitive user information A is encrypted using an encryption
scheme with an associated encryption key K in order to generate encrypted user information
A'.
[0078] Encryption is the process of encoding information in such a way that only authorised
parties can access the information (after decrypting the encrypted version of the
information). In the present invention, the sensitive user information A is encrypted
using an encryption key K to generate an encrypted user information A'. The encrypted
user information A' is ciphertext that is incomprehensible without the proper encryption
key for decrypting it. This means the encryption key is required in order to decrypt
the encrypted user information A' and access the sensitive user information A.
[0079] The method of the present invention is not limited to a specific type of encryption
and may employ any encryption scheme suitable for producing the encrypted user information
A' that may only be decrypted using at least one encryption key. For example, the
encryption scheme may be a symmetric-key scheme or an asymmetric-key scheme.
[0080] In symmetric-key encryption schemes the key used to encrypt plaintext into ciphertext
is identical to the key used to decrypt that ciphertext back into plaintext. In the
context of the present invention, this means that the verification platform must discard
the encryption key used to encrypt the sensitive user information A. That is, the
same encryption key used to encrypt the sensitive user information is the same key
necessary to decrypt the information.
[0081] The Advanced Encryption Standard (AES) is a well-known symmetric-key algorithm with
proven security that is based on a "substitution-permutation network". More specifically,
the algorithm transforms a 128-bit plaintext block into 16 bytes that are arranged
(substituted) into a 4x4 matrix in order to undergo several rounds of shifting, mixing,
and combining with a round key (permutation) before outputting the resulting ciphertext.
The decryption process performs the same steps using the same key for the same number
of rounds, but the steps are applied in reverse order.
[0082] An asymmetric-key scheme (also known as a public-key scheme) will use different keys
to encrypt and decrypt information. A public key (which may be shared widely) is used
to encrypt information and a corresponding private key (known only to the owner) may
be used to decrypt the information. Attempting to decrypt an encrypted message using
the public key will not decrypt the message and return the original information. In
the context of the present invention, this means that the verification platform must
discard the private key but may keep the public key, as it cannot be used to decrypt
the encrypted user information A'.
[0083] Rivest-Shamir-Adleman (RSA) and elliptic-curve cryptography (ECC) are both common
asymmetric cryptographic techniques. RSA exploits the difficulty of factoring the
product of two large prime numbers while ECC algorithms take advantage of the complexity
of finding the discrete logarithm of a random elliptic curve element (the private
key) compared to a publically known base point (the public key). The private key is
the key necessary to decrypt the information and is passed to the supervisor.
[0084] Both symmetric and asymmetric schemes are suitable for use in the present invention,
provided that the chosen scheme employs a non-trivial encryption algorithm which renders
the sensitive user information A unavailable without the correct decryption key. In
each example, a key necessary for decrypting the information is passed to the supervisor
and is not stored by the platform.
[0085] After encrypting the sensitive user information A (step S103 above), the verification
platform 16 creates and stores an authorisation request record R in a verification
database 20 (step S104).
[0086] The authorisation request record R comprises the unique supervisor identifier S and
the encrypted user information A'. Storing the record R in a database provides an
association between the unique supervisor identifier S and the encrypted user information
A' that the verification platform 16 can retrieve if necessary at a later time.
[0087] Before sending an authorisation request message to a supervisor device 12 (step S106
below), the verification platform 16 may encode the encryption key K into an authorisation
request message (step S105).
[0088] After encrypting the sensitive user information A (step S103 above), the verification
platform 16 sends an authorisation request message to a supervisor device 12 (step
S106). The authorisation request message comprises the encryption key K and a request
for authorisation in response.
[0089] The format of the authorisation request message depends on the unique supervisor
identifier S. For example, if the unique supervisor identifier S is an email address
then the authorisation request message may be an email or an API request to an application
used by the supervisor and associated with the email address. In an alternative example,
if the unique supervisor identifier S is a phone number or MSISDN then the authorisation
request message may be an SMS, MMS, or IP-based message.
[0090] The request for authorisation in response asks the supervisor to grant or refuse
authorisation for processing of the personal data, including the sensitive user information
A, of the user. This request may be implicit in the authorisation request message
or may be explicitly included in the message or added by a separate application. The
request for authorisation in response may be used to inform the supervisor of the
circumstances which have led to the supervisor receiving the authorisation request
message. For example, informing the supervisor that the user, who they are responsible
for, is attempting to register a profile on an online service or website.
[0091] The authorisation request message may request the minimum level of authorisation
required for a registration process to be completed or, alternatively, it may request
also additional levels of authorisation. For example, this may be permission to use
the sensitive user information A in a service that the online service provider does
not currently perform.
[0092] Optionally, the authorisation request message may comprise the sensitive user information
A, the encrypted user information A', or a link to view or retrieve A or A'. This
allows the supervisor to check the sensitive user information and be fully aware of
what they are being requested to authorise.
[0093] The authorisation request message may comprise the encryption key in a variety of
different forms. Preferably, the authorisation request message comprises a magic link
to enable the supervisor to provide authorisation and return the encryption key with
low user friction. A magic link is an authenticated URL that allows passwordless authentication
of the supervisor (device) when the link is activated. Alternatively, the authorisation
request message uses different means to authenticate the supervisor; this may be,
for example, a login form requiring username and password, or a code to be entered
on a permissions service used by the supervisor.
[0094] The authorisation request message may provide the supervisor with a binary choice
of whether to grant authorisation for the requested use of the sensitive user information
A. Alternatively, the authorisation request message may include several permissions
that can be selectively granted or withheld according to the supervisor (i.e. the
supervisor can provide bespoke consent to decide how and by whom the sensitive user
information A may be used).
[0095] In an exemplary use of a magic link, the URL may appear as "verification.com/access?token=abcd1234"
and the verification platform will have an API endpoint "/access" to handle the link
when it is clicked. The link is unique with the token in the URL corresponding to
the unique supervisor identifier S so that, when the link is clicked, the verification
platform is able to retrieve information about the supervisor to whom the token belongs.
Optionally, the token is encrypted before being encoded into the URL; if this is the
case then the verification platform must decrypt the token before retrieving information
about the supervisor. Optionally, the encryption key is also encoded into the URL
as part of the token; if this is the case then the encryption key is itself encrypted
or hashed before its inclusion into the magic link for increased security. Alternatively,
the magic link does not comprise the encryption key and is used to authenticate the
supervisor before the key is provided by different means, e.g. as a cookie attached
to the authorisation response message or retrieval from a secure web resource.
[0096] If a symmetric encryption scheme was used to encrypt the sensitive user information
A, then the encryption key K included in the authorisation request message is identical
to the encryption key used to encrypt the sensitive user information A in step S103.
If an asymmetric encryption scheme was used to encrypt the sensitive user information
A, then the encryption key included in the authorisation request message is different
to the encryption key used to encrypt the sensitive user information A in step S103.
[0097] After sending an authorisation request message to a supervisor device 12 (step S106
above), the verification platform 16 discards the sensitive user information A and
the encryption key (step S107).
[0098] As the verification platform 16 has discarded the encryption key it has no means
of decrypting the encrypted user information A'. Though the verification platform
16 may still be storing the encrypted user information A' without authorisation from
the supervisor this is not prohibited by the relevant regulations, such as COPPA and
GDPR. This is because the encrypted user information A' does not count as the personal
data of the user if the sensitive user information A cannot be retrieved using the
encrypted user information A'.
[0099] Discarding both the sensitive user information A and the encryption key while having
sent the authorisation request message, comprising the encryption key, to the supervisor
results in the verification platform 16 being unable to access or possess the sensitive
user information A unless the supervisor returns the encryption key.
[0100] If a symmetric encryption scheme was used in step S103, then the encryption key discarded
is the encryption key used to encrypt the sensitive user information A. However, if
an asymmetric encryption scheme was used in step S103, then the (private) encryption
key must be discarded and the (public) encryption key may be stored or discarded for
data minimisation.
[0101] After discarding the sensitive user information A and the encryption key (step S107
above), the user verification method may further include that the verification platform
16 receives an authorisation response message from the supervisor device 12 (step
S108).
[0102] The authorisation response message comprises a received encryption key. If a symmetric
encryption scheme was used to encrypt the sensitive user information A, then the received
encryption key is identical to the encryption key used to encrypt the sensitive user
information A in step S103 and included in the authorisation request message in step
S106. If an asymmetric encryption scheme was used to encrypt the sensitive user information
A, then the received encryption key is the private key and is not identical to the
encryption key used to encrypt the sensitive user information A but is identical to
the encryption key included in the authorisation request message in step S106. Optionally,
the authorisation response message comprises a notice of consent that describes the
level of consent that has been given by the supervisor for use of the sensitive user
information A.
[0103] After receiving the authorisation response message (step S108 above), the verification
platform 16 decrypts the encrypted user information A' using the received encryption
key (step S109).
[0104] If a symmetric encryption scheme has been used, as the received encryption key is
identical to the encryption key used to encrypt the sensitive user information A,
the verification platform 16 can decrypt the encrypted user information A' in order
to access the sensitive user information A. If an asymmetric encryption scheme has
been used, the received encryption key is the correct private key required to decrypt
the encrypted user information A' and so the sensitive user information A may be accessed.
Since authorisation has been granted by the supervisor, the requested storing and/or
using the sensitive user information A is not prohibited by the relevant regulations.
[0105] If an authorisation request record R was created in step S104, this step includes
using the unique supervisor identifier S to retrieving the authorisation request record
R from the verification database 20 so that the encrypted user information A' can
be accessed for decryption.
[0106] Optionally, after decrypting the encrypted user information A' (step S109 above),
the verification platform 16 sends a verification grant message to a registration
platform 14 (step S110).
[0107] The verification grant message comprises the sensitive user information A and, optionally,
the unique supervisor identifier S and/or the notice of consent.
[0108] In a scenario where the verification platform 16 is performing the user verification
method on behalf of a verification request from a registration platform 14, sending
the verification grant message to the registration platform 14 provides the registration
platform 14 with the sensitive user information A and informs the registration platform
14 that authorisation has been granted for the requested use of the sensitive user
information A. Receiving the verification grant message comprising the unique supervisor
identifier S allows, for example, the registration platform 12 to associate the grant
of authorisation with the unique supervisor identifier S so that subsequent verification
requests may be controlled, prohibited or accelerated. If the registration platform
12 has stored a record of the unique supervisor identifier S then the record may be
updated to associate the grant of authorisation with the unique supervisor identifier
S.
[0109] Alternatively, after discarding the sensitive user information A and the encryption
key (step S107 above), the user verification method may further include that the verification
platform 16 receives a refusal response message from the supervisor device 12 (step
S111).
[0110] The refusal response message indicates to the verification platform 16 that the supervisor
has refused to grant authorisation for the requested processing of the sensitive user
information A. Optionally, the refusal response message may comprise a notice of refusal
that describes why authorisation was refused by the supervisor and/or a request for
the encrypted user information A' to be discarded by the verification platform 16.
[0111] Optionally, after receiving the refusal response message from the supervisor device
12 (step S111 above), the verification platform 16 discards the encrypted user information
A' (step S112).
[0112] Although continuing to store the encrypted user information A', without any means
of decrypting it, does comply with the relevant regulations, the encrypted user information
A' may be discarded for data minimisation. Furthermore, the supervisor and/or the
user with whom the encrypted user information A' is associated may prefer that the
encrypted user information A' is not stored and cannot be accessed.
[0113] If an authorisation request record R was created in step S104, this step includes
retrieving the authorisation request record R from the verification database 20 so
that the encrypted user information A' can be located and subsequently discarded.
[0114] Optionally, after receiving the refusal response message from the supervisor device
12 (step S111 above), the verification platform 16 sends a verification refusal message
to a registration platform 14 (step S113).
[0115] The verification refusal message may comprise the unique supervisor identifier S
and the refusal response message.
[0116] In a scenario where the verification platform 16 is performing the user verification
method on behalf of a verification request from a registration platform 12, sending
the verification refusal message to the registration platform 12 informs the registration
platform 12 that authorisation for the requested use of the sensitive user information
A has been refused. Receiving the verification refusal message comprising the unique
supervisor identifier S allows, for example, the registration platform 12 to associate
the refusal of authorisation with the unique supervisor identifier S so that subsequent
verification requests may be controlled or prohibited. If the registration platform
12 has stored a record of the unique supervisor identifier S then the record may be
updated to associate the refusal of authorisation with the unique supervisor identifier
S.
[0117] Alternatively, after discarding the sensitive user information A and the encryption
key (step S107 above), the user verification method may further include waiting for
a predetermined period of time to expire (step S114).
[0118] The predetermined period of time may be any length of time, for example, one day,
two days, one week, or one month. Furthermore, the predetermined period of time is
not fixed. In other words, a predetermined period of time used in a first verification
method may be different to a predetermined period of time used in a second verification
method.
[0119] Optionally, after the predetermined period of time has expired, the supervisor is
unable to send an authorisation response message. In this scenario the verification
method must be repeated in order for authorisation to be granted, this may require
the user to initiate a registration process again.
[0120] After waiting for the predetermined period of time to expire (step S114 above), the
verification platform 16 discards the encrypted user information A' (step S115).
[0121] Although continuing to store the encrypted user information A', without any means
of decrypting it, does comply with the relevant regulations, the encrypted user information
A' may be discarded for data minimisation.
[0122] If an authorisation request record R was created in step S104, this step includes
using the unique supervisor identifier S to retrieve the authorisation request record
R from the verification database 20 so that the encrypted user information A' can
be accessed for discarding.
[0123] Optionally, after waiting for the predetermined period of time to expire (step S114),
the verification platform 16 sends a verification expiry message to a registration
platform 14 (step S116). The verification expiry message may comprise the unique supervisor
identifier S.
[0124] In a scenario where the verification platform 16 is performing the user verification
method on behalf of a verification request from a registration platform 14, sending
the verification expiry message to the registration platform 14 informs the registration
platform 14 that authorisation for the requested use of the sensitive user information
A has been not been granted within the predetermined period of time. Receiving the
verification expiry message comprising the unique supervisor identifier S allows,
for example, the registration platform 12 to associate the authorisation request expiry
with the unique supervisor identifier S so that subsequent verification requests may
be controlled or prohibited. If the registration platform 12 has stored a record of
the unique supervisor identifier S then the record may be updated to associate the
authorisation request expiry with the unique supervisor identifier S.
[0125] Performing the verification method described above and shown in figure 2 allows an
online service provider to seek permission to store and use PII covered by data protection
regulations without first storing the PII and breaching those regulations. Encrypting
the sensitive user information A and discarding the verification platform's copy of
the key necessary for decryption ensures that the supervisor is the sole party capable
of providing access to the sensitive user information A.
[0126] Figure 3 shows a process flow outlining a user registration method performed by a
registration platform 14 for a user incapable of providing digital consent. The user
registration method may be used by an online service provider to ensure they do not
illegally use PII of users to whom data protection regulations are applicable. The
user registration method may be, for example, a user registration method for a website
or online service such as a video game.
[0127] First, in step S201, the registration platform 14 receives sensitive user information
A and user consent information.
[0128] The sensitive user information A of the user registration method may be described
in the same manner as the sensitive user information A detailed above in the user
verification method.
[0129] The user consent information is associated with the user and enables the registration
platform to determine whether the user is capable of providing digital consent. For
example, the user consent information may comprise the age of the user. In another
example, the user consent information may comprise a psychiatric disorder held by
the user.
[0130] The sensitive user information A and the user consent information may be received
directly from a user device 10 or, alternatively may be received from a person other
than the user such as a service provider.
[0131] After receiving the sensitive user information A and the user consent information
(step S201 above), the registration platform 14 determines, in step S202, whether
the user is capable of providing digital consent.
[0132] For example, if the user consent information comprises the age of the user, the registration
platform 14 may determine whether the age of the user is below a digital consent age
threshold in the relevant jurisdiction.
[0133] If the user is not capable of providing digital consent, the registration platform
receives, step S203, a unique supervisor identifier S.
[0134] The unique supervisor identifier S of the user registration method may be described
in the same manner as the unique supervisor identifier S detailed above in the user
verification method.
[0135] The unique supervisor identifier S may be received directly from the user or, alternatively
may be received from a person other than the user such as a service provider.
[0136] Optionally, after receiving the unique supervisor identifier S (step S203 above),
the registration platform 14 creates and stores a registration request record in a
registration database 18 (step S204).
[0137] The registration request record comprises the unique supervisor identifier S. Storing
a record comprising the unique supervisor identifier S allows the registration platform
14 to save a registration state associated with the unique supervisor identifier S.
This may prevent, for example, the supervisor receiving multiple requests for authorisation
while a previous request for authorisation is still pending, and has not been addressed
by the supervisor, or when authorisation has been refused.
[0138] After receiving the unique supervisor identifier S (step S203 above), the registration
platform 14 sends, step S205, the sensitive user information A and the unique supervisor
identifier S to a verification platform 16.
[0139] Sending the sensitive user information A and the unique supervisor identifier S to
a verification platform 16 allows the verification platform 16 to verify whether a
supervisor of the user has granted authorisation for the use of the sensitive user
information A and, if authorisation has not previously been granted, request authorisation
for the use of the sensitive user information A.
[0140] The verification platform 16 may be a separate entity to the registration platform
14. Alternatively, the verification platform 16 and registration platform 14 may both
be integrated into a single system.
[0141] After sending the sensitive user information A and the unique supervisor identifier
S to the verification platform 16 (step S205 above), the registration platform 14
discards, in step S206, the sensitive user information A.
[0142] After discarding the sensitive user information A, the registration platform 14 does
not hold any personal data of the user incapable of providing digital consent and
does not have any means for accessing such personal data. Therefore, the registration
platform 14 and the operator of the registration platform 14 comply with the relevant
regulations.
[0143] Optionally, after discarding the sensitive user information A (step S206 above),
the registration platform 14 receives, step S207, a verification grant message from
the verification platform 16.
[0144] The verification grant message comprises a received sensitive user information A
and, optionally, a notice of consent.
[0145] The received sensitive user information A is identical to the sensitive user information
A that was received in step S201 and discarded in step S206. Receiving the sensitive
user information A from the verification platform 16 indicates to the registration
platform 14 that authorisation has been granted for the requested use of the sensitive
user information A.
[0146] The notice of consent of the user registration method may be described in the same
manner as the notice of consent detailed above in the user verification method.
[0147] Optionally, after discarding the sensitive user information A (step S206 above),
the registration platform 14 receives, step S208, a verification refusal message from
the verification platform 16.
[0148] The verification refusal message indicates to the registration platform 14 that the
supervisor has refused to grant authorisation for the requested processing of the
sensitive user information A.
[0149] Optionally, the verification refusal message comprises a notice of refusal that describes
why authorisation was refused by the supervisor.
[0150] Optionally, after discarding the sensitive user information A (step S206 above),
the registration platform 14 receives, step S209, a verification expiry message from
a verification platform 16.
[0151] The verification expiry message informs the registration platform 14 that authorisation
for the requested use of the sensitive user information A has not been granted within
a predetermined period of time.
[0152] It will be appreciated that elements of the verification method described in steps
S101 to S116 may be performed in combination with elements of the registration method
described in steps S201 to S209.
[0153] Figure 4 shows a process flow of a registration and verification method performed
by a system. The process flow shows an example of the interactions between the registration
platform 14 and the verification platform 16, as well as those by the user and supervisor,
where authorisation is granted by the supervisor.
[0154] Figure 4 shows a process flow of a registration and verification method combining
the registration method, described above and shown in figure 3, with the verification
method, described above and shown in figure 2, in a scenario where authorisation for
processing of the sensitive user information A is granted by the supervisor. Figure
4 also shows the interactions between the registration platform 14 and the verification
platform 16, as well as the interactions and decisions made by the user and the supervisor.
[0155] While the present invention has been described in the context of certain platforms,
it will be understood that the principles described may be implemented through any
arrangement of suitable computing devices or distributed computing devices. A platform
may be thought of as a remote server operating over a network. The principles are
not limited to any specific operating system or architecture and indeed are designed
to be system or platform agnostic. The device described above as a user device or
a supervisor device may be any sort of suitable device such as a personal computer,
tablet computer or smartphone.
[0156] It is important to note that while the present invention has been described in the
context of a fully functioning system, those of ordinary skill in the art will appreciate
that the processes of the present invention are capable of being distributed in the
form of a computer readable medium of instructions and a variety of forms and that
the present invention applies equally regardless of a particular type of signal bearing
media actually used to carry out distribution. Examples of computer readable media
include recordable-type media such as floppy disks, a hard disc drive, RAM and CD-ROMs
as well as transmission-type media such as digital and analogue communication links.